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Self Building CDM requirements / responsibilities Advice needed.


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I know this has been discussed lots and I’ve read many but would like direct advice on our project…

 

We are about to demolish (ourselves) our existing bungalow and replace with a timber frame house.

 

We will be using 1 company to do groundwork/foundations.

 

 Another company will supply/erect the frame to wind/watertight membrane.

 

 I’m going to do as much as possible myself, prepping site, roof, first fix etc.

 
I had a meeting on site this week with architect, engineer, groundwork company and timber frame company. 
 

There were lots of questions/comments about CDM responsibilities; who is construction manager etc. I was more than a little daunted as haven’t really explored this. Slightly happier after reading up but would like to know where my responsibilities lie, tips on making this smooth and any useful resources.

 

 Thank you in advance for everyone’s help/advice.

Edited by junglejim
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  • junglejim changed the title to Self Building CDM requirements / responsibilities Advice needed.
  • 3 months later...

Risk assessments are a good idea regardless of simply ticking a box to show you tried.

Standard forms help a lot but you could just write it down on blank paper. 

What am I about to do?

What are the risks? Falling, tripping,  electrocution and so on.

What can I do to reduce them?

How will I do this?

 

Each of your contractors should do their own.

You do yours.

You look at the general site risks that may require measures. 

Then do it or police it to a reasonable extent.

 

A separate thing is that you probably need to submit a demolition notice to the L.A. 6 weeks before starting.

 

 

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Posted (edited)

 

Copied straight from Health and Safety Regulations – Self Build Portal , which was linked from here Construction - CDM 2015 FAQ's - Self build (hse.gov.uk)

 

"The self builder acts as their own project manager, employing individual trades at different times. In this instance, the self builder steps out of the DIY arena, because they are taking control of construction work. Where a self builder controls the way in which construction work is carried out by a person at work, they must comply with all the matters outlined in Part 4 of CDM 2015. This requirement is set out in Regulation 16 of CDM 2015, which effectively replaces Reg 26 in CDM 2007, this is not a new requirement. In this scenario the self builder will in effect become a contractor. In this case the HSE will expect self builders to demonstrate sufficient health and safety capability to meet the requirements of Part 4 of CDM 2015. Individual contractors will be expected to be able to advise the self builder on any specialist matters within their own work activities. The expectation on a self builder in this position will be on co-ordination and management , not on direct supervision of contractors on site. The self builder is entitled to expect contractors to plan, manage and monitor their own work in compliance with the CDM Regulations."

 

Read some of this,

Construction Publications, Free Leaflets - HSE -   A printed off file of these is handy to have on site. And Covers what @saveasteading said

 

Have you [someone on your behalf] submitted an F10 notification form?

 

Edited by Blooda
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3 minutes ago, Blooda said:

self builder steps out of the DIY arena,

I think this links with a post last week about a kit supplier not being happy with the welfare on site or the quality of the foundations. It's the clients job to coordinate.

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1 hour ago, Blooda said:

Have you [someone on your behalf] submitted an F10 notification form?

 

 

Not all self-builds will be notifiable.

 

HSE must be notified of the project if:

  • It will last longer than 30 days and involve more than 20 workers at the same time; or
  • It will exceed more than 500 person days

If the project is notifiable, then as you note, the HSE must be notified online using the F-10 form.

 

Bear in mind that this is time on site, so you don't count off-site fabrication of timberframes or staircases etc.

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3 hours ago, garrymartin said:

 

Not all self-builds will be notifiable.

 

HSE must be notified of the project if:

  • It will last longer than 30 days and involve more than 20 workers at the same time; or
  • It will exceed more than 500 person days

If the project is notifiable, then as you note, the HSE must be notified online using the F-10 form.

 

Bear in mind that this is time on site, so you don't count off-site fabrication of timberframes or staircases etc.

 

Agreed, I think we are on the same page, hence it was asked as a question ? 

 

The principal contractor should carry out their resourcing assessments, to establish if it is a notifiable project, and this should be in the Construction Phase Plan. It is better to have taken consideration, Than not.

 

A Construction Phase Plan of proportionate scale can be produced here:-

CDM Wizard - CITB

 

There was no way we could get our estimate down to less than 500 person days, even before COVID extended the plan from 40 weeks to 2 1/2 years for the build.  Given 40 weeks x 6 days x 2 people [Me and SHWMBO] = 480 person days [before any real trades have clocked their hours], hence we notified the HSE, via F10.

 

 

 

 

 

 

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15 minutes ago, Blooda said:

Given 40 weeks x 6 days x 2 people [Me and SHWMBO] = 480 person days [before any real trades have clocked their hours], hence we notified the HSE, via F10.

 

That's very interesting. Have you assumed you should count your [and SWMBO] time in the 500 days or have you seen specific guidance for that?

 

My understanding was that as self-builders, we are not ‘at work’ in the meaning of the Health and Safety at Work etc Act 1974, so our time would not be included in the 500 days.

 

 

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44 minutes ago, garrymartin said:

our time would not be included in the 500 days.

I think safety is the key here, whoever that might be.

I've only had any hassle from HSE when an 'enemy' has tried to land us in it, or a neighbour is scared of non existent asbestos.

 

HSE are probably more inclined to visit if a substantial looking project, seen in passing,  is not registered. If they are on their way back from a gruesome accident then beware. They can't visit every job, but will be inclined to go to that one. 

 

So I'm saying that it isn't worth fiddling the figures to avoid the easy process of registering.

500 hours is some measure of risk level and complexity. It doesn't matter who is doing it.

If your site is in good order then they are friendly and helpful.

 

If the plan is to use cheap quotes without risk assessments and safety kit, then that might be a reason to try to hide the project. But the consequences after an accident would be greater.

 

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4 minutes ago, saveasteading said:

I think safety is the key here, whoever that might be.

Agreed. I wasn't implying you don't need to follow H&S guidance, merely that if it hasn't been notified, it may not need to be.

 

My own plan (when my appeal is allowed...) is to notify via F-10 regardless (I can't really see a downside) but then ensure I try to remain as a Domestic Client throughout - i.e. I don't tell people how to do the work, I contract them to deliver an agreed outcome. The common sense guidance is then more about a few key principles and H&S chats over a cup of tea than it is about reams of guidance and procedures.

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1 hour ago, garrymartin said:

My understanding was that as self-builders, we are not ‘at work’ in the meaning of the Health and Safety at Work etc Act 1974, so our time would not be included in the 500 days.

 

 

 

That single statement could have a whole thesis written on it. 🤔 And people still would not agree.

 

We notified, as in essence it a simple process, and not notifying does not negate any H&S commitments.

 

 

 

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1 hour ago, Blooda said:

We notified, as in essence it a simple process,

Did you get any visits or other contact?

 

1 hour ago, garrymartin said:

I don't tell people how to do the work,

I cannot do that, either in keeping my tongue still, or claiming ignorance.

But its an interesting point.

 

Be sure not to drill through the vapour barrier? 

You have not sealed the laps on the vapour barrier?

Don't dig there, as there is a cable?

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2 minutes ago, saveasteading said:

Be sure not to drill through the vapour barrier? I've been really careful not to drill through the vapour barrier; I'm sure you'll do the same

You have not sealed the laps on the vapour barrier? Shouldn't those laps on the vapour barrier be sealed?

Don't dig there, as there is a cable? Remember, there's a cable there. I wouldn't want to dig through that...

 

You can sort of get the same result without actually directing the work... 😉

 

But I get your point. Regulation 16 is clear that "(3) A domestic client who controls the way in which any construction work is carried out by a person at work must comply with the requirements of this Part so far as they relate to matters within the client’s control." so Part 4 requirements will pretty much always be in scope, but only the stuff I can realistically be expected to control - I'm comfortable with that.

 

At the end of the day, much of this is common sense - doing what is reasonably practicable is all you can realistically be expected to do.

 

The most important thing for me will be contracting with organisations/people that understand *their* responsibilities with regard to CDM and H&S in general.

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@junglejim we are currently demolishing a bungalow with basement and attic, we have asbestos although low grade and I used to work for licensed asbestos removal company so familiar with rules. I have written method statements and risk assessments for asbestos and demolition via www.haspod.com it’s basically has template which enables you to edit and save, think is £6 per document they also have documents on CDM. I write method statements and risk assessments for event work so felt comfortable writing them from scratch but it helped to follow a template so nothing was missed as had not worked on a building site for some decades.

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  • 1 month later...

I've been informed by a chartered architect I know that compliance with CDM regs is worryingly inadequate in many projects. These legally mandated protocols are often neglected, posing significant risks.

 

A concerning trend has emerged where individuals, not certified as chartered architects, assume the role of principal designers. This group includes those with some design background or even no formal training at all, yet they present themselves as qualified architects. Unlike chartered architects, who face severe consequences, including potential deregistration for malpractice, these impostors operate with little oversight.

 

These unqualified professionals are frequently the biggest culprits in failing to implement essential HSE requirements. Their services are cheaper, attracting cost-conscious clients and tradespeople who prefer less paperwork, despite the increased legal risks.

 

The architect I know highlighted the systemic issue of enforcement. The government lacks the resources to proactively ensure compliance, with regulatory actions often triggered only after an incident occurs. Even then, penalties are minimal unless there are severe consequences.

 

However, it’s not all bleak. Tools like the CDM Wizard can significantly ease the compliance burden. Drawing from my experience in the oil and gas industry, where HSE standards are rigorously maintained, I believe that once properly set up, such tools can simplify adherence to HSE protocols across projects.

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What worked for me

 

Being the self builder, I was on site at all times and doing a big lump of work myself. Used CDM Wizard (Phone app) for all risk assessments, these were stored until house was signed off.

 

One contractor company on site, at any time. They controlled their own work, as they were independent companies, so under my control. They worked to drawings I provided and they quoted for work against these drawings. I did quality checks to ensure work complete satisfactory manner, if not they rectified at their own expense, prior to invoice being paid. 

 

My manhours were free, so not deemed as employed on site. 

 

42 minutes ago, MBT6 said:

concerning trend has emerged where individuals, not certified as chartered architects, assume the role of principal designers

That could be me then. But was also the project manager. My engineering background is managing jobs way more complex than house.

 

I read and digested building regs knew as much or more than any contractor we had on site. I was in the review process for all architect drawings, none were complete until I had reviewed and or commented and given a green light. Fell out with the first architect as he didn't like it, so found one that would accept a two way design process and me as the client, as someone that would actively review and comment on drawings, make changes and say no when not happy.

 

I come from a different field, but all relevant experience. You work to drawings, contractors quoted against drawings and specifications, if something is not clear, you ask for clarification - this occurred during quote process and at the work site. If a contractor didn't want to play ball, he didn't get the work.

 

On 02/05/2024 at 15:00, garrymartin said:

notify via F-10 regardless

I didn't bother, didn't meet the 500 person day or numbers on site criteria. No point putting head above the parapet to get shot for no reasons.

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Beware producing lots of paperwork (or virtual paperwork) rather than actually dealing with risks. An Inspector would rather a safe site with minimal (or nil) bureaucracy then find multiple files that nobody looks at.

 

I've been on a site where the national contractor had 3 lever arch files but couldn't find the section he was being asked for. The site agent tried to fob hse off onto me, as the subcontractor responsible for the interesting works at that time...cladding at 8m. I showed HSE my 12 pages and then had a walk round and he was happy...but not with the big contractor.

 

So yes, have written stuff but not too much and make sure it is relevant.

1 hour ago, MBT6 said:

A concerning trend has emerged where individuals, not certified as chartered architects, assume the role of principal designers.

Your Architect is either selling himself or doesn't know or respect what other professionals do.

CDM isn't normally one of the key skills of Architects, in my experience, and they tend to suggest the client engages a CDM consultant.

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2 hours ago, MBT6 said:

The government lacks the resources to proactively ensure compliance,

The HSE lacks the resources because the government has cut them.

Inspectors would previously visit a contractor every few years for a chat, and an overview, even when no problems had occurred or were foreseen. They saw it as working together for better safety.

Little builders with no F10 would only meet an inspector after  a  nasty accident.  The punishments can be severe.

A stop notice is a big deal too. 

 

I think I met HSE maybe 8 times in 300 notifiable projects. 

Did I ever recount about when I phoned HSE to report a dangerous situation on my own job? 

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When finding trades, suss out if they are safe workers, and remind people to work safely. Do a First Aid course and have good kit. Have basic protective equipment available and get them to use it (this can be very difficult). Don’t leave people  alone on site if you can possibly help it.

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